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TX7: Pre-Jones GPS placement with only RS on court order held valid

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Texas statute permitted placement of a GPS device on reasonable suspicion prior to Jones, when this was one placed on defendant’s car. No court had ever held, prior to now, that the reasonable suspicion standard was too low and probable cause was required. Therefore, the good faith exception would be applied. It also did not matter that the vehicle would be driving to New Mexico. Taylor v. State, 2013 Tex. App. LEXIS 10923 (Tex. App. – Amarillo August 28, 2013). The consent to search was shown to be voluntary, and the owner as passenger gave it. The search did not exceed the scope of consent. $5,000 in United States Currency v. State, 2013 Tex. App. LEXIS 11118 (Tex. App. – Waco August 29, 2013).* Officers’ entry into the common area of a University of Kentucky fraternity house to do a knock-and-talk on a single room did not violate defendant’s reasonable expectation of privacy. Milam v. Commonwealth, 2013 Ky. App. LEXIS 131 (August 30, 2013).

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